Tag: Risk Management

Risk gauge

Safety 2018: Where Are You in the Transition to Risk?

Workplace safety is evolving as safety professionals seek to shift the philosophy of their organizations away from one of basic compliance to one based on reducing risk. At the American Society of Safety Professionals’ (ASSP) Safety 2018 Conference and Exposition being held in San Antonio, Texas, Pam Walaski, Health and Safety Director for GAI Consultants, […]

How to Avoid RMP

Are you close? You must have more than a threshold amount of a listed substance in process at your facility for the Risk Management Program requirements of the Clean Air Act Section 112(r) to apply. If your facility’s source is close to the threshold for a particular substance, you may be able to limit the […]

RMP under Scrutiny

The EPA recently issued an updated request for information (RFI) seeking public comment on updating its Risk Management Program regulations, and a notice of proposed rulemaking is being prepared.  In the original RFI, the Agency noted that it is looking for specific feedback on whether the list of Risk Management Program (RMP)-regulated substances should be […]

RMP—No Release but a Huge Fine Anyway

It’s hard to swallow a huge fine for what might have happened. But, as part of its efforts to comply with the president’s EO to improve safety and security at chemical facilities, the EPA is hunting down companies that are required to develop RMPs but have not even though there has not been a release […]

EPA Adds New TRI Reporting Category for Nonylphenol

EPA Adds New TRI Reporting Category for Nonylphenol Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) requires facilities that manufacture, process or otherwise use chemicals listed in the TRI to report a variety of data regarding those chemicals. The EPA is authorized to add new chemicals to the TRI when those chemicals […]

Four RMP Documentation Violations to Avoid

Four RMP Documentation Violations to Avoid 1) Failure to include all the required documentation for the alternative release scenarios for the chemical pipe leak and natural gasoline vapor cloud fire as required by 40 CFR 68.39(b). 40 CFR 68.39(b) establishes the offsite consequences analysis documentation requirements for alternative release scenarios that include a description of […]

Recent RMP Settlements Underscore Compliance Pitfalls

Recent RMP Settlements Underscore Compliance Pitfalls On September 24 and 29, 2014 the EPA announced settlements with three different companies in two states for violations of to RMP regulations.  The first two settlements were at facilities in Idaho, one a corn-based ethanol production facility in Burley and the other a manufacturer of agricultural chemicals in […]

Sector Highlights from the 2013 Greenhouse Gas Reporting Program

Sector Highlights from the 2013 Greenhouse Gas Reporting Program In 2013 1,572 power plants reported, which is down from 1,589 in 2011 and 1,601 in 2012. This sector consists of facilities that produce electricity by combusting fossil fuels and/or biomass and the emissions from this sector are solely from stationary fuel combustion sources, although carbon […]

How to Qualify for RMP Program Level 1

How to Qualify for RMP Program Level 1 After determining that a propane storage facility is subject to the RMP regulation, the next step is to identify which program level applies. The U.S. Environmental Protection Agency (EPA) established three program levels that reflect different levels of risk and, subsequently, the level of effort required to […]